We are requesting the State of Virginia to repeal the two clauses in 12VAC5-125-90 that neither protect the consumer nor have a positive effect on public health, but only add cost and hurt profit margins at a time when both manufacturers and retailers are struggling:

• Date of Delivery

  • Because putting a date of sale on the label is not required and is no longer a practice carried out at retail, this requirement holds no purpose.

  • The 2015 IABFLO Labeling document omitted the DOD requirement, and at that time, Hollander, as did several other manufacturers, removed the DOD from our law labels.

  • To go to the extraordinary expense of changing the labels to add the DOD, for a reason that does nothing to protect or benefit the consumer, serves no purpose.

• 1/8” (3mm) Font Size on “Certification Clause”

  • Only one other state at this time has this requirement (and it is not enforced), so in the interest of having consistency in a law label that will be acceptable to all states, without adding unnecessary expense to the manufacturer for a regulation that serves no benefit to the consumer, we request that this be repealed.

Though Virginia has not been actively enforcing these two regulations, third party laboratories are now failing testing submitted by manufacturers because the regulations are still on the books and have been added to the most recent ISPA manual.

It is for these reasons, we are respectfully requesting repeal of the two regulations.